Here is MCGA's comment letter on EPA's proposal to cut the Renewable Fuel Standard

You have until midnight on Monday, July 27 (that’s today!), to officially submit your comments and tell the Environmental Protection Agency that the Renewable Fuel Standard (RFS) is working for all Americans. Click here to submit your comments.

Meanwhile, here is the official RFS comment letter from Northfield family farmer and Minnesota Corn Growers Association (MCGA) President Bruce Peterson, submitted on behalf of the MCGA’s more than 7,000 members.

July 27, 2015

Administrator Gina McCarthy
Air and Radiation Docket and Information Center
U.S. Environmental Protection Agency
Mailcode: 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

RE: Docket ID No. EPA-HQ-OAR-2015-0111

Dear Administrator McCarthy:

On behalf of the more than 7,000 members of the Minnesota Corn Growers Association (MCGA), we appreciate the opportunity to comment on the proposed rule for the Renewable Volume Obligations of the Renewable Fuel Standard.

The recent announcement by the Environmental Protection Agency (EPA) to scale back Renewable Volume Obligation (RVO) numbers as called for by Congress in the Renewable Fuel Standard (RFS) is a major step backward for America’s energy policy. Thanks to the RFS, the United States is relying less on foreign oil than ever before. The use of ethanol in our fuel supply also means American drivers are reducing harmful vehicle emissions and paying less at the pump.

EPA’s proposed RVO numbers fall in line with the fictional 10 percent blend wall and well below actual ethanol production. The blend wall is a myth created by the oil industry. The “Big Five” oil companies use rigid franchise and branding agreements, restrictive supply contracts, outlandish labeling requirements, punitive penalties and other heavy-handed tactics to discourage retail fuel stations from selling higher ethanol blends like E15 and E85.

Unbranded or independent fueling stations are four to six more times likely to offer E85 than one of the “Big Five” oil brands. Independent stations are over 40 times more likely to offer E15.

The American ethanol industry and the corn farmers who support it are more than capable of producing enough ethanol to far exceed the oil industry’s fictional 10 percent blend wall. Here in Minnesota, we’re already well beyond the make-believe blend wall. According to the Energy Information Administration, ethanol made up 12.2 percent of the Minnesota fuel supply in 2013.

Bruce Peterson

MCGA President Bruce Peterson farms in Northfield.

Not only do Minnesotans have access to nearly 300 stations that offer E85, they also can fill up with E15 at 30 stations. Since the Fall of 2013, a broad coalition that includes MCGA has invested in ethanol infrastructure and helped install more than 120 flex-fuel pumps throughout the state. These pumps give consumers the choice of filling up with regular unleaded, E15, E30 or E85.

That’s real consumer choice. Many of the retailers with flex-fuel pumps often report that drivers choose E15 if given the option because it’s less expensive, better for air quality and approved for use in all vehicles manufactured in 2001 or after.

Minnesota’s recent success in dispelling the myth of the blend wall follows a tradition of being a pioneer in the ethanol industry. We were the first state to blend 10 percent ethanol in our supply. This decision helped clean the air in the Twin Cities metro area and brought the region back into attainment status with the EPA.

There are 21 ethanol plants in Minnesota (nearly half of which are farmer-owned cooperatives) that support nearly 13,000 jobs. Ethanol has rejuvenated the rural economy in many parts of our state, leading to better schools, updated infrastructure and vibrant Main Street businesses. For every $1 invested to build a Minnesota ethanol plant, more than $8 has been returned to the economy.

Over 11,000 corn farmers grow and supply corn to Minnesota’s ethanol industry. From 2000-11, ethanol added an average of $2.11 in value per bushel. Improved corn prices meant more economic activity in rural areas and a ripple effect throughout the entire agricultural economy that had an impact in the Twin Cities and non-farming areas.

As you can see, a reduction in the RVO numbers would make an impact far beyond our fuel tanks. It would also result in job losses, reduced air quality and fewer rural economic development opportunities. There are already enough barriers and obstacles to ethanol in this country. By cutting the RFS, EPA is creating yet another one.

For example, E10 has been granted a 1 pounds-per-square inch (psi) waiver in the summer months. However, E15 has a lower vapor pressure than E10, but has not been granted the same waiver. Refiners are able to make reformulated gasoline (RFG) with Reid Vapor Pressure as low as 7.8 psi. If refiners were required to make RFG, there would be no need for a 1 psi waiver on E10 or E15 and there would be additional environmental benefits.

Instead of cutting the RFS, EPA would be better off working to address issues like these. Imagine obstacles like Reid Vapor pressure being removed from the advancement of E15. If all gasoline contained 15 percent ethanol, we’d replace 7 billion gallons of foreign oil and remove as much as 8 million tons of greenhouse gas emissions from the air in one year.

In summary, lower RVO numbers are bad for drivers, bad for farmers and bad for all Americans. We’re already producing enough ethanol to smash through the fictional oil industry blend wall, and could be producing more if some ill-advised regulations and other obstacles were removed.

Americans want cleaner-burning and more affordable choices at the pump. Corn farmers have proven that they’re capable of growing enough corn to produce food, feed, fiber and fuel. Now is not the time to take America’s energy policy backward. Now is the time for EPA to preserve the RFS and keep American energy policy headed in the right direction.

Thank you for the opportunity to comment on this important issue.





Bruce Peterson
Minnesota Corn Growers Association

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